ESG Disclosure in connection with the Sustainable Finance Disclosure Regulation

In accordance with the Sustainable Finance Disclosure Regulation (the SFDR) and the Taxonomy Regulation, DEC Alliance Management B.V., being the Manager of the DEC Alliance Fund Cooperatief U.A., provides the following statements.

Qualification of the Fund under the SFDR and the Taxonomy Regulation
The Manager does not promote any environmental and/or social characteristics with the Fund (“light green” within the meaning of Article 8 SFDR), nor does the Fund have sustainable investments as its objective (“dark green” within the meaning of Article 9 SFDR). The Manager therefore only complies with the disclosure requirements under Article 6 SFDR, as further set out in this annex.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Integration of sustainability risks into investment decision-making procedures
The Manager acknowledges that events or circumstances related to environmental, social or governance matters, if they occur, may have a real or potentially significant negative impact on the value of the Fund’s investments. The Manager therefore takes these sustainability risks into consideration when assessing and managing investment opportunities in portfolio companies as part of the Fund’s portfolio. Sustainability risks are therefore part of the Manager’s selection and due diligence policy as well as its risk management policy.
 

Remuneration policy in relation to the integration of sustainability risks
Compliance with the Manager’s ESG policy regarding the integration of sustainability risks into the investment decision-making process may form part of the performance assessment of the board members within the Manager’s board, as defined in Article 5 SFDR.

No principal adverse impact (PAI) statement by the Manager
In the area of sustainability, the Manager limits itself to assessing the impact of sustainability risks on the portfolio companies it manages.

The Manager currently does not specifically take into account the potential impact of investment decisions on environmental and social matters, employment, respect for human rights, and the fight against corruption and bribery (the “sustainability factors” within the meaning of Article 4(1)(a) SFDR), and therefore does not prepare an annual “statement on principal adverse sustainability impacts” (hereinafter: “PAI Statement”). This is mainly based on the following reasons:

 

• The Manager does not promote with the Fund any specific environmental or social characteristics, nor does the Manager pursue sustainable investments with the Fund. It is therefore not meaningful to measure the possible impact of investment decisions in these areas.

• If the Manager were to decide to take into account the negative sustainability effects of investment decisions, a detailed annual PAI Statement would have to be drawn up in a prescribed format, as required under the SFDR. Preparing such statements requires consideration of numerous detailed requirements, many of which are not relevant to the type of investments the Manager includes in its portfolios. The Manager considers it appropriate to issue a PAI Statement annually only if it were explicitly promoting environmental or social characteristics or pursuing sustainable investments, as in that case investors would be able to assess whether the commitments made by the Manager in this regard are being met.

The above may be reconsidered under different circumstances, for example if the Manager’s investment policy changes, if preparing a PAI Statement becomes less burdensome than is currently the case or appears to be, or if the majority of investors require a PAI Statement.